F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Collaboration Session 

Fifth of Six in 2019 and 2020

June 10, 2020
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Topics

• Industry’s Progress Toward Full Implementation as of March 31, 2020

• Positive Train Control Safety Plan (PTCSP) Update

• Statutory and Regulatory Flexibility Following the December 31, 2020, 

Deadline

• Statutory and Regulatory Failure-related Reporting Requirements

• Future Amendments to FRA-certified PTC Systems

1
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

High-level Overview of Industry’s Progress 

Toward Fully Implementing PTC Systems 

as of March 31, 2020

2
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Progress Toward Full Implementation

As of March 31, 2020

• Status of Host Railroads’ PTC-governed Operations

o As of March 31st, PTC systems were in operation or advanced testing (RSD)

on over 56,500 (98%) of the almost 58,000 required route miles—a 2%

increase from December 31, 2019

o Three (3) railroads commenced RSD during Q1 of 2020, and four (4) railroads

placed all route miles into RSD during that quarter

o Two additional Class I railroads placed all subdivisions into PTC operations

o FRA received four (4) PTC Safety Plans during Q1 and as of March 31, 2020,

has fourteen (14) PTCSPs under review

3
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Interoperability Continues to Progress

As of March 31, 2020

• Status of Interoperability

o 48.5% of host-tenant relationships are interoperable (total 229)

o Operational/Complete: 111 relationships

o Testing: 73 relationships

o Installing: 21 relationships

o Not Started: 5 relationships

o Not Reported: 19 relationships 

o Interoperability achieved by host railroad type:

o Class I Railroads: 59%

o Amtrak: 25%

o Commuter Railroads: 32%

o Other Host Railroads: 52% 

4
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

2020 ‘At-risk’ Criteria

• As of March 31, 2020:

o Four (4) railroads came off the at-risk list from December 31, 2019, reducing 

the list to four (4) railroads

• Criteria:

o Expected date to submit PTC Safety Plan

o Percentage of route miles governed by PTC (including RSD)

o Severity of technical issues impacting testing and roll-out schedule

o Percentage of interoperable tenant railroads

• Measured:

o Quarterly (Q4 2019, Q1 2020, Q2 2020, and then monthly)

o Letters to railroads and governing bodies (for any commuter railroads)

o List published when data is released

5
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plan Update

6
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plans and FRA Certification Status 

(Host Railroads Only)

7

• Safety Plan & Certification Status

o 13 Certified PTC Systems (including Conditionally Certified Systems)

o 7 I-ETMS non-vital overlay, and 1 I-ETMS mixed system

o 2 ACSES II vital overlay

o 1 E-ATC vital overlay

o 1 CBTC mixed system

o 1 ITCS vital overlay

o 15 PTC Safety Plans under review

o 8 I-ETMS

o 3 ACSES II

o 4 E-ATC

o 9 PTC Safety Plans not yet submitted 

o 7 RFAs expected
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

PTC Safety Plan Review – FRA Insights

8

• PTC Specialists are focusing on early review of documentation 

(pre- and post-submission)

o Railroads have been very responsive and timely in updates

o FRA has suspended reviews while waiting for updates to submissions

o Except for ACSES II systems, FRA has prioritized review and approval of 

safety plans that will be used as a baseline (E-ATC, I-ETMS non-vital 

overlay), and this process is nearing completion

o Contract support will be available to PTC Specialists from the end of June 

to provide safety engineering manpower

• Reminder of key considerations for PTC Safety Plan preparation

o Document all variances to the associated Type Approval

o Update hazard log and risk assessment reflecting Type Approval variances, 

operational differences, functional differences, and test data results

o Update human factors analysis to reflect railroad operations

o If using a baseline approval, ensure all comments to the baseline are 

addressed prior to submission
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Overview of the Statutory and Regulatory 

PTC Flexibility Following the 

December 31, 2020 Deadline

9
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Overview of Certain Post-deadline Flexibilities

I. Background

• The Positive Train Control Enforcement and Implementation Act of 2015 requires an FRAcertified and interoperable PTC system to govern operations on all main lines subject to

the statutory mandate by December 31, 2020.

• However, the Early Adoption subsection of the statute recognizes that certain PTC system

failures (e.g., initialization failures, cut outs, and malfunctions) may occur after December 31,

2020. See 49 U.S.C. § 20157(j).

o When Is the Early Adoption Period? Oct. 29, 2015 → One year after the last Class I railroad obtains

PTC System Certification and finishes fully implementing a PTC system on all its required main lines

• Reminder: A railroad must comply with the safety assurance and reporting requirements under

49 U.S.C. § 20157(j)(1)–(4). For example, if an FRA-certified PTC system fails to initialize, cuts

out, or malfunctions, the affected railroad shall make reasonable efforts to determine the cause

and adjust, repair, or replace any faulty component causing the failure in a timely manner.

10
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Overview of Certain Post-deadline Flexibilities

II. Early Adoption Provisions

Beginning with 49 U.S.C. § 20157(j)(1)

• The statute temporarily prohibits FRA—until approximately December 31, 2021—from imposing or 

enforcing the operational restrictions under FRA’s S&TC regulations (49 CFR § 236.567) and PTC 

regulations (49 CFR § 236.1029) when a PTC system “fails to initialize, cuts out, or malfunctions, 

provided that such carrier operates at an equivalent or greater level of safety than the level achieved 

immediately prior to the use or implementation of its [PTC] system.”

• The statute provides the same temporary relief—from the operational restrictions under 49 CFR 

§§ 236.567 and 236.1029—to any Class II or Class III railroad operating pursuant to an exception 

under 49 CFR § 236.1006(b)(4) (≤4 non-PTC-governed movements per day), which otherwise would 

require “that movement [to] be made in accordance with § 236.1029.” See 49 CFR § 236.1006(c).

11
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Overview of Certain Post-deadline Flexibilities

III. Timeline Applicable to Railroads with a 2020 Deadline*

For illustrative purposes, the table below summarizes the pertinent authorizations and prohibitions under

the Early Adoption subsection (49 U.S.C. § 20157(j)) and/or FRA’s regulations, including 49 CFR

§§ 236.1006(b)(3) and 236.1029(g).

12

Calendar Year 2021 

(Last Year of Early Adoption Period)

Calendar Year 2022 January 1, 2023 and Thereafter  A train may operate on a PTCmandated main line even if:

o The PTC system failed to 

initialize; or

o The PTC system failed en

route (including malfunctions 

and cut outs).  The operational restrictions under 

49 CFR §§ 236.567 and 236.1029 

do not apply. 

 A train may operate on a PTCmandated main line even if:

o The PTC system failed to 

initialize; or

o The PTC system failed en

route (including malfunctions 

and cut outs).  The operational restrictions under 

49 CFR §§ 236.567 and/or 

236.1029 do apply.

 A train may operate on a PTCmandated main line even if:

o The PTC system failed en

route (including malfunctions 

and cut outs).  The operational restrictions under 

49 CFR §§ 236.567 and/or 

236.1029 do apply.

*This overview focuses on the framework applicable to railroads 

that obtained FRA’s approval of an “alternative schedule and 

sequence” with a December 31, 2020, deadline, 

under 49 U.S.C. § 20157(a)(3).
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Overview of Certain Post-deadline Flexibilities

IV. Timeline Applicable to Railroads with a 2018 Deadline*

For illustrative purposes, the table below summarizes the pertinent authorizations and prohibitions under

the Early Adoption subsection (49 U.S.C. § 20157(j)) and/or FRA’s regulations, including 49 CFR

§§ 236.1006(b)(3) and 236.1029(g).

13

Calendar Year 2021 

(Last Year of Early Adoption Period)

January 1, 2022 and Thereafter  A train may operate on a PTC-mandated main line even 

if:

o The PTC system failed to initialize; or

o The PTC system failed en route (including 

malfunctions and cut outs).  The operational restrictions under 49 CFR §§ 236.567 

and 236.1029 do not apply. 

 A train may operate on a PTC-mandated main line even 

if:

o The PTC system failed en route (including 

malfunctions and cut outs).  The operational restrictions under 49 CFR §§ 236.567 

and/or 236.1029 do apply.

*This overview focuses on the framework applicable to railroads 

that fully implemented an FRA-certified and interoperable PTC 

system by December 31, 2018.
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Statutory and Regulatory 

Failure-related Reporting Requirements

14
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

I. Permanent Regulatory Reporting Requirements

To ensure PTC system failures are properly communicated to all 

affected parties, FRA’s PTC regulations require coordination 

among, and reporting by, railroads, vendors, and suppliers, 

under 49 CFR §§ 236.1023, Errors and malfunctions, 

and 236.1029, PTC system use and failures. 

15
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

I. Permanent Regulatory Reporting Requirements (Cont’d)

Example #1 – Vendors and suppliers: • 49 CFR § 236.1023(b)(2)–(3) & (h) – PTC system and product suppliers and vendors shall:

o Promptly report, to each railroad using the product, any safety-relevant or safetycritical failures, defective conditions, or previously unidentified hazards in their PTC 

system, subsystem, or component, in addition to the recommended mitigations, pending determination of the root cause and final corrective actions; and

o Notify FRA of any safety-relevant failure, defective condition, or previously unidentified 

hazard discovered by the vendor or supplier and the identity of each affected and 

notified railroad.

• 49 CFR § 236.1023(f) lists reporting instructions and content requirements for FRA 

purposes (e.g., due w/i 15 days of discovery).

16
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

I. Permanent Regulatory Reporting Requirements (Cont’d)

Example #2 – Post-PTC System Certification: • 49 CFR § 236.1023(e) – A railroad must notify FRA and the applicable vendor/supplier if:

o The frequency of a safety-relevant hazard exceeds the thresholds in the railroad’s 

PTCSP, or 

o The safety-relevant hazard has not been previously identified in the appropriate risk 

analysis. 

• See 49 CFR § 236.1023(f) for reporting instructions (e.g., due w/i 15 days of discovery). • For FRA purposes, please e-mail directly to: FRAPart2361023Notification@dot.gov

17
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

I. Permanent Regulatory Reporting Requirements (Cont’d)

Example #3 – Post-PTC System Certification: • 49 CFR § 236.1023(k) – A railroad must comply with the standard reporting requirements 

under 49 CFR part 233 if it experiences a failure of its PTC system resulting in a more 

favorable aspect than intended or other condition hazardous to the movement of a train. 

→ 49 CFR §§ 233.5, Accidents resulting from signal failure, & 233.7, Signal failure reports

o Examples listed in FRA’s conditional PTC System Certifications:

• Failure to enforce required braking applications and speed restrictions;

• Overrun of an authority boundary due to late braking or an inaccurate braking 

algorithm; and

• Authority sent by the dispatcher to the train crew, where such authority is either not 

promptly transmitted, not recorded, or erroneously modified by the system. 

18
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

I. Permanent Regulatory Reporting Requirements (Cont’d)

Example #4 – Post-full implementation of a PTC system: • 49 CFR § 236.1029(h) – After a railroad fully implements an FRA-certified and 

interoperable PTC system on its PTC-mandated main lines, the railroad must submit an 

annual report by April 16th regarding the PTC system failures that occurred during the prior 

calendar year. At a minimum, the report shall “identify failures by category, including but 

not limited to locomotive, wayside, communications, and back office system failures.”

• Voluntary Aspect – For consistency, the annual report could also include the same 

categorizations as under 49 U.S.C. § 20157(j)(4)—i.e., “initialization failures, cut outs, and 

malfunctions.” 

• For railroads whose deadline for full PTC system implementation is December 31, 2020, 

the first annual failure report will be due April 16, 2021, and each April 16th thereafter. 

19
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

II. Temporary Statutory Reporting Requirement

On June 5, 2020, the Office of Management and Budget (OMB) approved the mandatory 

Statutory Notification of PTC System Failures (Form FRA F 6180.177, OMB Control No. 2130-

0553). • Electronic Web Form – https://safetydata.fra.dot.gov/PTCSystemFailuresFRAForm177/ • For Detailed Information and Background – o Initial 60-day Federal Register notice – 84 Fed. Reg. 72121 (Dec. 30, 2019)

o The final 30-day Federal Register notice summarizing and responding to industry’s 

comments – 85 Fed. Reg. 15022, 15025–27 (March 16, 2020)

As a reminder, the temporary failure-related reporting requirement under 49 U.S.C. § 20157(j)(4):

• Applies only to FRA-certified PTC systems that are in operation, and 

• Is effective from only October 29, 2015, until approximately December 31, 2021. 

20
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Reporting of Various PTC System Failures 

II. Temporary Statutory Reporting Requirement (Cont’d)

As a reminder, as the statute authorizes, FRA established via the OMB-approved Statutory 

Notification of PTC System Failures (Form FRA F 6180.177): (1) an alternative reporting 

location (instead of submitting the notifications to the appropriate FRA region), and (2) an 

alternative reporting deadline (instead of within 7 days of each occurrence).

Important Notes:

• FRA’s website enables host railroads to upload bulk data. Specifically, the website contains

an Excel template, which is available for downloading and uploading (labeled “Import”).

• By early July, each SIR user will be e-mailed web-form log-in instructions, including a

password. Access for additional users can be requested via the website as well.

• If you have any questions or issues while using the website or uploading the Excel

template to the website, please send an e-mail to PTC.correspondence@dot.gov. 21
22
23
24
25

• Failure to Initialize: Any instance when a PTC system fails to activate on a locomotive or train, unless the PTC system successfully activates 

during a subsequent attempt in the same location or before entering PTC territory. For the types of PTC systems that do not “initialize” by 

design, a failed departure test is considered a “failure to initialize” for purposes of this reporting requirement, unless the PTC system 

successfully passes the departure test during a subsequent attempt in the same location or before entering PTC territory.

• Cut Out: Any disabling of a PTC system, subsystem, or component en route, including when the PTC system cuts out on its own or a person 

cuts out the system, unless the cut out was necessary to exit PTC-governed territory and enter non-PTC territory.

• Malfunction: Any instance when a PTC system, subsystem, or component fails to perform the functions mandated under 49 U.S.C. 20157(i)

(5), 49 CFR part 236, subpart I, or the applicable host railroad’s PTC Safety Plan.
26
27
28
29
30
IsTenant OrganizationName IsPTCGoverned TotalTrainsOperatedOnHost FailureTypeCode Subdivision TotalFailuresDuringPeriod

FALSE ABCD TRUE M AMBOY 19

FALSE ABCD TRUE C AMBOY 10

FALSE ABCD TRUE I AMBOY 10

TRUE ACADIANA RAILWAY COMPANY TRUE 4 C CROWLEY LINE 8

TRUE ACADIANA RAILWAY COMPANY TRUE 4 I CROWLEY LINE 1

TRUE ACADIANA RAILWAY COMPANY TRUE 4 M CROWLEY LINE 17

TRUE ACADIANA RAILWAY COMPANY TRUE 4 C OPELOUSAS LINE 17

TRUE ACADIANA RAILWAY COMPANY TRUE 4 I OPELOUSAS LINE 12

TRUE ACADIANA RAILWAY COMPANY TRUE 4 M OPELOUSAS LINE 17

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 C ADIRONDACK 10

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 C SYSTEM 7

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 I ADIRONDACK 18

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 I SYSTEM 3

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 M ADIRONDACK 10

TRUE ADIRONDACK SCENIC RAILROAD TRUE 43 M SYSTEM 17

TRUE ALEXANDRIA TRAINS FALSE

TRUE ABERDEEN RAILROAD TRUE 12 C PIEDMONT 15

TRUE ABERDEEN RAILROAD TRUE 12 I PIEDMONT 1

TRUE ABERDEEN RAILROAD TRUE 12 M PIEDMONT 5

TRUE ABERDEEN RAILROAD TRUE 12 C SANDHILLS 12

TRUE ABERDEEN RAILROAD TRUE 12 I SANDHILLS 0

TRUE ABERDEEN RAILROAD TRUE 12 M SANDHILLS 6

Sample Excel upload sheet

Note: data is not real data and is just serving as an example

31
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Other Guidelines for the Statutory Notification of System Failures

Based on FRA’s Analysis of Previously Submitted Data

In several cases, industry submissions provided more data than is required. These guidelines are reflected in the 

Excel template available for download on the website, in “Data Submission Instructions” & “Sample Submission.” • For each tenant railroad, provide the total # of that tenant railroad’s trains on the host

railroad in general. The “TotalTrainsOperatedOnHost” field should be the same for each row for

each individual tenant railroad. For example, if Tenant X ran 100 times on Subdivision A and 50

times on Subdivision B, each “TotalTrainsOperatedOnHost” value for Tenant X on all subdivisions

should be 150. Otherwise, the web form will only take the first value. Furthermore, this field

“TotalTrainsOperatedOnHost” is not required for the host railroad and can be left blank. • The “Total Number of PTC-required Train Miles” and “Total Number of Scheduled

Attempts at Initialization” should be reported only for the host railroad’s operations.

These numbers should not include any tenant railroad’s operations. • A tenant railroad’s name should be reported consistently throughout a report. There

should not be variations in the naming/spelling of one tenant railroad in the same report. • The subdivisions should correspond to the PTC-equipped subdivisions (or track

segments, districts, territories, main line, branches, or corridors) in a railroad’s PTC

Implementation Plan.

32
F E D E R A L R A I L R O A D A D M I N I S T R A T I O N

Future Amendments to 

FRA-certified PTC Systems

33